Southchem Inc - Executive Summary |
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Southchem Inc. Executive Summay, Durham, NC 1. Accidental Release Prevention and Emergency Response Policies We at Southchem Inc are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Chemical distribution. We have 5 regulated substances present at our facility. These substances include Hydrogen Fluoride(Hydrofluoric Acid], Ammonia (aqueous), Formaldehyde (solution), Chlorine and Sulfur Dioxide (anhydrous). Ammonia (aqueous),and Formaldehyde (solution) are repackaged and stored for distribution. Hydrogen Fluo ride (Hydrofluoric Acid), Chlorine, and Sulfur Dioxide (anhydrous) are only stored for distribution. The maximum inventory of Hydrogen Fluoride (Hydrofluoric Acid) at our facility is 33,264.00 lbs. while Ammonia (aqueous), Formaldehyde (solution), Chlorine and Sulfur Dioxide (anhydrous) are present at our facility in quantities of 24915.62 lbs.,24776.31 lbs.,18750.00 lbs. and 10350.00 lbs. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Ammonia Hydroxide. In this scenario 59515 lbs. of Ammonia (conc 20% or greater) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited by a system of administrative controls. Passive mitigation systems such as dike(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of limiting the spread of product. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 0.8 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Chlorine involves a release from Chlorine storage. The scenario involves the release of a 150 lb cylinder. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 1 minute. Under neutral weather condition s, the maximum distance to the toxic endpoint of 0.0087 mg/L is 0.2 miles. The alternative release scenario for Sulfur Dioxide (anhydrous) involves a release from Sulfur Dioxide storage. The scenario involves the release of a 150 lbs. cylinder. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 1 minute. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L is 0.2 miles. The alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) involves a release from Hydrofluoric acid storage. The scenario involves the release of 378 lb. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario. The release is also assumed to be controlled by sprinkler system(s). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L] is 0.06 miles. The alternative release scenario for Ammonia (conc 20% or greater) involves a release from Ammonia Hydroxide. The scenario involves the release of 727 lb. Of Anhydrous Ammonia. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as berms and enclosures are taken into account to calculate the scenario. The release is also assumed to be controlled by neutralization. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L is 0.19 miles 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition, since Southchem aquired the building in 1981. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Southchem Inc maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years. Any findings related to the hazard analysis are addressed in a timely manner. The most rece nt PHA/update was performed on 06/01/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Southchem Inc maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Southchem Inc has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity Southchem Inc carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others ; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Southchem Inc to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 06/01/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conduct ed as a regular practice at Southchem Inc. The most recent review was performed on 01/01/1990. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Southchem Inc conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 6/1/99. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Southchem, Inc promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All report s are retained for a minimum of 5 years. Employee Participation Southchem, Inc truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Southchem Inc has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulat ed substance occur. 5. Five-year Accident History Southchem Inc has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Southchem, Inc carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Durham County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Southchem Durham is spending $4.5 million over the next several years to improve environmental controls at the facility. Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The National Association of Chemical Distributors requirements of the Responsible Distribution Process which require Southchem to provide update training and information to its employees to help improve safety at our facility. |